California ARB posts final modifications for ZEV rule on fast refueling/battery exchange for public comment
The staff of the California Air Resources Board (ARB) has posted for public comment current final modifications for the Zero Emission Vehicle Regulation for 15 days. (Earlier post.) Statutorily, depending upon the comments received, ARB staff may either make further modifications and resubmit to Board for further consideration; failing that, the Board will adopt the new regulatory language.
These final tweaks to the ZEV rule involve the allocation of ZEV credits for different types of ZEV vehicles and the handling of the associated fast-refueling accreditation, which includes the possible use of battery-swapping.
Background. At the 24 October 2013 public hearing, ARB approved for adoption proposed amendments to the ZEV rule, which requires auto manufacturers to develop and commercialize ZEV (e.g., plug-in hybrid, battery-electric and hydrogen fuel cell technologies).
The modification addressed three minor problems: changes to effectuate an agreement between other states adopting California motor vehicle emission standards including the ZEV regulation (Section 177 states) and regulated manufacturers; provisions to ensure ZEVs are delivered for sale in California every year; and modifying the fast refueling definition;
The Board also directed staff to incorporate further modifications to the regulation’s fast refueling credit provisions to ensure that such credit for Type IV and V ZEVs through 2017 model year only be awarded based on actual use and be fuel neutral.
California categorizes ZEVs by Type (I to V), based on the zero-emissions range. The longer the range, the higher the Type and the more credits generated for the automaker. Automakers can use ZEV credits to meet their statutory requirements for ZEV sales in California, or, as is the case, for example, with Tesla, sell the credits to other automakers as a non-insignificant revenue stream.
Under provisions adopted in 2001, ZEVs with the ability to refuel to 95% of full capacity within 15 minutes are allowed to earn more credit under the Type IV and Type V ZEV definitions. The Board directed staff to retain the fast refueling accreditation, so long as it is based on real-world use of the fast refueling and maintains fuel neutrality.
Modifications. In these latest modifications, staff alters existing language to require manufacturers to submit fast refueling usage data in order to qualify for fast refueling credits. Manufacturers seeking to earn fast refueling credits will be required to submit the miles attributed to fast refueling during 12 consecutive months and the total miles driven for all vehicles of that vehicle model during the same 12 months.
This requirement would not apply to manufacturers of fuel cell electric vehicles.
The original modifications had removed the ability to qualify for fast refueling by battery swapping; that provision is now stricken, but is replaced with the need to demonstrate the utility of the system.
For Model Year 2009 through 2017, a vehicle will be considered a Type III, Type IV or Type V ZEV if it has the capability to accumulate at least 95 miles of UDDS range in 10 minutes or less; at least 190 miles of UDDS range in 15 minutes or less; or 285 miles of UDDS range in 15 minutes or less, respectively.
For Model Years 2015 through 2017, inclusive, “capability to accumulate” means the ZEV’s refueling system has been demonstrated to the satisfaction of ARB’s Executive Officer as actually accumulating the miles required under this subdivision within the given time period for the claimed ZEV type, based on refueling events. To receive fast refueling credits manufacturers must apply to ARB with the information and documentation.—Modifications to ZEV rule
The required information and documentation includes total fleet miles attributed to fast refueling use in a 12 consecutive month period and total fleet miles in the same 12 month period; and documentation of each fast refueling event.
Fast refueling credits are to be calculated as follows:
- Fast refueling miles / total miles = M
- 4 credits = ZEV credit per each Type III ZEV
- 4 + (M) x (1 credit) = ZEV credit per each Type IV
- ZEV 4 + (M) x (5 credits) = ZEV credit per each Type V ZEV
|ZEV Credit table|
|Tier||Calendar Year in Which ZEV enters service|
|Type IV||5||4 to 5|
|Type V||7||2012-2014: 7|
2015-2017: 4 to 9
|Underline indicates modification|